IR 05000244/1979008

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IE Insp Rept 50-244/79-08 on 790501-18.Noncompliance Noted: Inadequate Review of Surveillance Test Results & Inadequate Sys Startup Procedure
ML17249A187
Person / Time
Site: Ginna Constellation icon.png
Issue date: 08/03/1979
From: Beckman D, Foley T, Keimig R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17249A181 List:
References
50-244-79-08, 50-244-79-8, NUDOCS 7910150073
Download: ML17249A187 (90)


Text

'U.S.

NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-244/79-08 Docket No. 50-244 Category:

C License No.

DPR-18 Priority:

Licensee:

Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649 Inspection conducted:

Ma 1-

, 1979 D.

.

c man, eactor Inspector T. Foley, React Inspector Inspectors Approved by R.

R.

K mig, C iei, Reactor Projects Section No. 1, R08NS Branch Facility Name:

R.

E. Ginna Nuclear Power Plant, Unit

Inspection at:

Ontario, New York date s

g ed

'7 d te ss ed ate sag e

Ins ection Summar

Ins ection"durin the eriod Ma 1-18,, 1979 (Re ort No.'50-'244/79-08)

reas ns ecte

outine, unannounce

~nspec ion y a regsona based inspector o

actions taken by the licensee in response to the event at Three Mile Island; actions taken in response to I'E Bulletin 79-06A, Revision 1; and review of licensed operator training, onsite inspection of engineered safety features, and onsite assesment of operating pro-cedures..

The inspection involved 154 inspector-'houi s onsite by two'NRC regional based inspectors.

Results:

Of the five areas inspected, no items of noncompliance were ouuserve in four areas.

Two items of noncompliance were observed in the fifth area (Infraction - inadequate review of surveillance test" results, paragraph 5; Infraction - inadequate system startup procedure, paragraph 3).

7910yg p Q,7+

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DETAILS

. 1.

Persons Contacted

  • Mr. W. Backus, Operations Supervisor Mr.

C. Edgar, I8C Foreman Mr. D. Gent, Results and Test Supervisor

  • Mr. G. Larriza, Technical Engineer
  • Mr. R. Morill, Training Coordinator
  • Mr. J.

Noon, Assistant Superintendent Mr. C. Peck,. Operations Engineer Mr. B. guinn, Health Physicist

  • Mr. T. Schuler, gC Engineer
  • Mr. B. Snow, Superintendent
  • Mr. S. Spector, Maintenance Engineer Mr. J. St. Martin, Project Liaison Engineer The inspectors also interviewed other licensee personnel including members of the operations, maintenance, health physics and general office staffs.
  • Denotes those present at-the exit'nterview.

2.

Onsite Review of 0 erator Trainin The inspector reviewed the training which had been administered to licensed operators as part of the approved Operator Requalification Program in accordance with Administrative Procedure A-102.14, Revision 0.

This review included training administered in response to the Three Mile Island Unit 2 (TMI 2) event as well as specific topics presented during routine program training sessions.

The inspector made the following determinations in regard to this training:

a.

All licensed operators and senior operators received training on the circumstances and chronology of the TMI-2 event including procedure changes both planned and already implemented as a result of IE Bulletin 79-06A.

The licensee's procedure review and revision effort is ongoing and will'esult in procedure changes being routed to'licensed personnel for self study as they are promulgated.

Additionally, the licensee has committed'to provide formal training sessions, as part of the requalification training,

l

which will address revised emergency procedures and the responses required by operators under emergency and abnormal conditions.

Operator Requalification. training administered prior to the TMI-2 event included those measures provided to assure that engineered safety features would be available, if required.

This training was included as a general topic in lectures on related systems and administrative controls during the past year.

In that the prior training given on these subjects was not specific to the circumstances of the TNI-2 event, the licensee has committed to provide specific training in the subject above including system features and administrative controls.

Routine operator requalification training has addressed the general measures provided in procedures and system features to ensure that automatic actuations of engineered safety features are not overridden except as provided in approved emergency procedures.

In response to the TNI-2 event and IE Bulletin 79-06A, the licensee issued written directives to the'perators on April 18, 19 and May 17, 1979, which stipulate the conditions under which automatic actuation of ESF equipment may be overriden.

The licensee's response to the IE Bulletin includes criteria for termination of safety injection flow following a small break LOCA which is at variance with the direction provided in the Bulletin.

This will be reviewed as a separate matter.

The direction provided to the operators in the above directive is consistent with the licensee's response.

Interviews of at least 2 licensed operators on each shift confirmed their understanding of the direction provided by licensee management.

Emergency and Operating procedures are being revised to reflect this guidance.

Specific requalification program training will be performed during the summer training schedule which will include ESF actuation'ignals, actions during safety injection, and conditions under which the system may be reset or secure 'I l

d.,

This 'training will be performed upon completion of the in-process procedure revisions.

The operators will continue to be made aware of individual procedure revisions, as they occur, via documented review of each issued change.

Training conducted to date in response to the TMI-2 event has included general discussion of containment isolation and isolation reset features which affect the control of radioactive liquids and gases.

The licensee has committed to conduct additional specific training in this regard during the lectures discussed in item (c) above.

In addition, the licensee will conduct training on the Liquid Waste System during the current requalification cycle.

e.

" Plant Operators and superv'isory personnel have been instructed in the provisions for early NRC notification of serious events.

These instructions have been and will continue to be discussed during operator training sessions as part of the licensee's response to IE Bulletin 79-06A.

Additionally, Emergency Procedure E-1.1, Safety Injection System Actuation, Revision 8, issued 5/1/79, and Site Contingency Procedure SC-1, Site Radiation Emergency (Shift Foreman and Control Room), Revision 8, issued 5/10/79, now include instructions for notification of the NRC consistent with the guidance in IE Bulletin 79-06A.

An existing phone line in the central room has been designated for this use pending installation of dedicated telecommunications presently being pursued by the NRC Telecommunications Branch.

The inspector noted during this review that specific instructions have been provided for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> notification of NRC for only Site Radiation Emergencies and valid

.

safety injection actuations.

The licensee stated that these instructions were considered to cover nearly all situations which would require one hour NRC notification.

Situations not defined by the procedures above will be referred to station supervision/management by on-shift personnel.

Station management will then direct the notification of NRC should they deem it appropriate.

Written guidance will be provided in the near future to ensure prompt referral of events subject to NRC notification to

l

-5-station-management.

This item will be followed as part of future reviews of licensee action taken pursuant to IEB 79-06A.

f.

The inspector conducted interviews with the operators on each shift to confirm their awareness and understanding of the existing criteria for operation of Reactor Coolant Pumps, the importance of maintaining forced RCS flow, and how to determine the degree of RCS subcooling as discussed in IE Bulletin 79-06.

As discussed elsewhere in this report, the licensee's response to IEB 79-06A is at variance with the bulletin's guidance in regard to these subjects.

The inspector confirmed that each operator interviewed was aware of the guidance/requirements promulgated by licensee management and facility procedures and had an understanding of the material discussed in the bulletin.

g.

On April 18, 1978, NRC representatives conducted on site briefings on the TNI-2 event and IE Bulletin 79-06A, Revision l.

All licensed personnel and key station management and supervisory personnel were required to attend that session or NRC conducted makeup sessions.

In conjunction with the licensee's requalification training program, the inspector conducted makeup sessions on May I and 9, 1979 for those personnel who had not previously attended such a session.

All required licensee personnel have received this briefing.

The matter of training for operators in the specific areas of (a)-

(d) above will also remain unresolved pending its completion by the licensee for all licensed personnel and review of that training by NRC: RI (244/79-08-01).

3.

Review of S stem Ali nment Procedures The inspectors reviewed valve/breaker/switch alignment procedures for all Engineered Safety Features systems against current engineering flow diagrams and electrical diagrams to verify adequacy of the alignment procedure l

-6-

'The following drawings were. utilized to conduct these reviews as well as those procedure reviews discussed elsewhere in this report.

TITLE Reactor Coolant System DRAWING NO.

33013-424 REVISION Safety Injection System - Sheet

33013-425 CVCS - Sheet 1, Section

CVCS - Charging Pump 5 Seal Schematic CVCS - Sheet

Waste Disposal System (Waste Gas System)

Sht.

Waste Disposal System-Sheet 2 of 2 Waste Disposal System-Sheet 1,

Page

33013-426 33013-427 33013-428 33013-429 33013-430 33013-431 Safety Injection System - Sheet

33013-432 CVCS - Sheet 1, Section

33013-433 Chemical and Volume Control System 33013-434 Auxiliary Coolant, Section

Auxiliary Coolant System Waste Disposal System, Sheet

Steam Generator Blowdown Station Service Cooling Water Main 8 Reheat System 33013-435 33013-436 33013-437 33013-522 33013-529 33013-534

l l

TITLE Turbine Plant Piping Diesel Generators Containment Vessel Air 8 Proof Test Floor 5 Equip. Drains, Waste Disposal System Aux. Bldg.

8I Containment Vessel Condensate System Feedwater System Elementary Wiring Diagram Booklet Drawing (Various Sheets)

DRAWING NO.

33013-539 33013-540 33013-541 33013-543 33013-544 10905 REVISION Various b.

The following system alignment procedures were reviewed to assure that at the completion of each procedure the respective systems were properly aligned to perform their intended functions.

The procedures so reviewed were:

(1)

Overall Plant Operations Procedures NUIIBER TITLE 0-1.1 Plant Heatup from Cold Shutdown to Hot Shutdown 0-1.1C Pre-Critical Technical Specification Check Sheet 0-1.1D Pre-Heatup Plant Requirement Check List 0-1.2 Plant from Hot Shutdown to Steady Load (2)

Reactor Plant Systems Operation Procedures NUMBER TITLE S-3.1B Preoperatiorial Line-Up of Boric Acid System REVISION

16

REVISION

J

-8-NUMBER TITLE REVISION S-3.1D Boron Control Valve Line-Up S-3.1E lA Boric Acid Storage Tank, Isolation/Restoration S-3.1F 1B Boric Acid Storage Tank, Isolation/Restoration S-3.1G Isolating, Flushing and Draining the "A"

Boric Acid Storage Tank for the Major Valve Tank or Piping Maintenance and Inspection S-3.1H Isolating, Flushing and Draining the "B"

Boric Acid Storage Tank for the Major Valve Tank or Piping Maintenance and Inspection S-8

  • Component Cooling Water System S-8A
  • Component Cooling Water System Startup

8 Normal Operation Valve Lineup S-13

"RHR Loop S-13A

  • RHR System Lineup for Safety Injection S-13B RHR Pump Isolation S-16A
  • denotes procedures discussed fUrthet:- in paragraph 4 of this repor t I

NUMBER TITLE REVISION S-16.9 S-16.10 S-16.11'harging the "A" Accumulator with Nitrogen Charging the "B" Accumulator with Nitrogen Monitoring and Enrichment of Accumulator Boron Concentration S-16.13 Water Make-Up to the Accumulators-S-16.14 Isolation/and Restoration of Safety Injection Pumps Suction Line from Boric Acid Tanks S-16.16 Safety Injection Pump Isolation S-16. 17 1C Safety Injection Pump Alternate Suction

Relief Valve 1817 Isolation for Maintenance S-17. 1

  • Containment Spr ay System-S-17.2 Spray Additive NaOH Tank Drain Down

S-17.3 Containment Spray Pump Isolation S-21. 1 S-21. 2 S-23. 1 1A Hydrogen Recombiner Purging 8 Operation

1B Hydrogen Recombiner Purging 8 Operation

  • 1A Containment Recirculation Fan Coolers

Pre-Startup S-23.2

  • 1B Containment Recirculation Fan Coolers Pre-Startup S-23. 3 S-23.4
  • 1C Containment Recirculation Fan Coolers Pre-Startup
  • 1D Containment Recirculation Fan Coolers Pre-Startup

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- 10-NUMBER TITLE REVISION S-23. 5 S-27.861 Post-Accident Charcoal Filter Operation

Relief Valve 861 S-27.887 Safety Injection Relief Valve 887 Isolation S-30.1

\\

  • Safety Injection System Val ve Position Verification

S-30. 2 S-30. 3

  • RHR System Valve Position Verification

"Auxiliary Feedwater System Valve Position Verification (3)

Turbine Plant 0 erations Procedures T-25 Instrument and Control Bus T-27.1 T-27.2

T-27.4

  • Diesel Generator Operation T-27.5 T-27.6 T-36.1 Station Service Water - Header Valve Alignment for Two Loop Operation

Diesel Startup Air Compressor Isolation

Diesel Fuel Oil Transfer Pump Isolation

T-41-A T-41B, Alignment of Auxiliary Feedwater System Prior to Power Operation Turbine Driven Auxiliary Feed Pump-Removal From Service

T-41C Turbine Driven Auxiliary Feed Water Pump-Restoration to Service After Maintenance

T-41D Motor Driven Auxiliary Feed Water Pump Isol ati on

I I

-11-c ~

Findings During review of Reactor Plant Systems Operations Procedure S-16A, Safety Injection System Alignment, Revision 14,- the inspector determined that the SI Loop A Cold Leg Injection Throttle Valve, V878E,

'as not included in the system alignment instruc-tions.

This valve is in the cold leg injection flow path and, if closed, would render the RCS Loop A injection flow path inoperable.

Upon identifi-cation of this omission, the licensee immediately entered containment and verified the valve to be open.

The valve was found in the locked open condition.

Upon further review by the inspector, it was determined that the valve was not included in the locked valve list of Administrative Pro-cedure A-52.2, Control of Locked Valves, Revision 24.

Procedure A-52.2 requires all valves which are locked to be listed and controlled by that procedure.

Failure to properly establish, implement, and maintain procedures for startup, operation and locked valve control of emergency core cooling systems is contrary to Technical Specification 6.8.1 and constitutes an Infraction level item of noncompliance (244/79-08-02).

. (2)

Review of the Reactor Plant Systems Operations Pro-,

cedures for the Auxiliary Feedwater System and Component Cooling Water System found that compre-hensive instructions for system switch and breaker alignments are not available.

The licensee's operating procedure program is based upon using procedures for all system status changes and there-fore provides proceduralized instructions for removal from and return to service of affected equipment based upon the specific evolution being performed.

As a result of this operating philosophy, the licensee had not previously identified a need to provide such instructions for the above systems.

The licensee acknowledged the inspector's concerns and committed to provide electrical alignment instructions in the procedures for Auxiliary Feed-water and Component Cooling Mater Systems within 60 days of the completion of this inspection.

This

I

'I

-12-matter is unresolved pending completion of the above action by the licensee and review by NRC:RI (244/

79-08-03).

In order to confirm the adequacy of the existing admin-istrative controls discussed above, the inspector directly observed the switch and breaker alignments of the two systems in question and determined that all equipment was properly aligned for normal operation and was capable of supporting emergency operation.

(3)

During the review of the procedures and drawings listed in paragraphs 3.a and 3.b above, and paragraph 5, the inspector identified a number of procedure and drawing errata which apparently resulted from editorial, typographical and drafting errors.

Each of the errata was reviewed by the inspector and,licensee management and each was found to have no apparent safety signi-ficance.

The list of all errata so identified was provided to the licensee for insertion into the facility's guality Assurance Program Preventive Action Request (PAR) System for disposition.

This item will remain unresolved pending the issuance of PAR's for the items by the licensee and review of the issued PAR's by NRC:RI (244/79-08-04).

4.

Verification of S stem Ali nment Using the licensee pr ocedures identified by asterisk (*) notes in paragraph 3 of this report, the inspectors directly verified system alignments for all accessibje valves, breakers and switches in the following systems:

Safety Injection System (HHSI, Accumulators)

Residual Heat Removal System Boric Acid/Boron Control Subsystems Component Cooling Mater System Containment Spray System (including Spray Additive Subsystem)

Containment Recirculation Fan Coolers

-13-Emergency Power Systems Station Service Mater System Auxiliary Feedwater System On May 8, 1979, the inspector also conducted a logbook review and direct verification of Main Control Board system status for ESF systems.

The verification included inspector performance of Operating Procedure 0-6.2, Main Control Board System Status Verification, Revision 5, and inspector observation of control board indication for the above systems.

All position and status indicators were correct for the current mode of operation and all control switches observed were properly aligned for automatic initiation of Engineer and Safety Features systems.

No items of noncompliance were identified, 5.

Review of Surveillance, Maintenance and Calibration Procedures The inspector reviewed current approved Periodic (surveillance)

Test procedures, Maintenance Instructions and Calibration Procedures to verify that when they are completed, systems will have been returned to an operable alignment.

The procedures tabulated below were reviewed in conjunction with the engineering flow diagram and electrical drawings noted in paragraph 3 in order to make this determination.

The inspector also reviewed the last"Periodic Test performed on each Engineered Safety Feature System to verify that acceptance criteria had been met.

The dates of performance of each periodic test reviewed are parenthetically listed with that test.

a.

Periodic Test Procedures NUMBER TITLE REVISION PT-2.1 PT-2.2 Safety Injection Pumps (April 23, 1979)

Residual Heat Removal System (April 19, 1979)

NUMBER TITLE-14-REVISION PT-2.3.1 Post Accident Charcoal Filter Dampers (May 8, 1979)

PT-2.7 PT-2.8, PT-2.9 Service Water System (April 12, 1979)

Component Cooling Water Pump System (April 19, 1979)

Check Valve Exercising quarterly Requirement (March 10, 1979)

PT-2.9.2 Accumulator Discharge Check Valves quarterly Exercising (March 24, 1979)

PT-2.9.3 Check Valve Exercising quarterly Requirement (866A and 866B)

(March 9, 1979)

PT-2;10.1 RCS and SI Header Check Valves (March 18,

.1 979)

PT-2.10. 2

- PT-3 PT-5.10 PT-5. 20

'PT-5. 30 PT-5.40 RHR System Core Deluge Check Valves 853A and 8538 (February 22, 1979)

Containment Spray Pumps and NaOH Additive System (April 24, 1979)

Process Instrumentation Reactor Protection Channel Trip Test (CHANNEL 1) (April 17, 1979)

Process Instrumentation Reactor Protection Channel Trip Test (CHANNEL 2) (April 17, 1979)

Process Instrumentation Reactor Protection Channel Trip Test (CHANNEL 3) (April 18, 1979)

Process Instrumentation Reactor Protection Channel Trip Test (CHANNEL 4) (April 18, 1979)

NUMBER TITLE-15-REVISION PT-5.50 PT-9 PT-10. 2 PT-10. 3 PT-11 PT-11.1 PT-12.1 Auto Stop Oil Pressure Switch and Relay Test (April 18, 1979)

Undervoltage and Underfrequency Protection 11A and 11B - 4160 Volt Buses (April 27, 1979)

Station Battery 1-B Load Test (April 5, 1979)

Station Battery lA Load Test (April 10, 1979)

60 Cell Battery Banks "A" and "B" (May 5,.

1979)

Heat Trace Circuitry Functional Check (May 5, 1979)

Emergency Diesel Generator 1A (May 4, 1979)

PT-12. 2 PT-15 Emergency Diesel Generator 1B (April 12, 1979)

Containment Purge Supply and Exhaust Damper Closure Time (October 23, 1975)

10 PT-15. 2 PT-16 PT-19.1 PT-20 PT-21 Bus 14 and 16 Voltage Transients Due to Safety Injection Pump Start When Fed With Offisite Power (June 29, 1977)

Auxiliary Feedwater System (May 10, 1979)

Component Cooling Water Pump Parameters (September 30, 1977)

Main Steam Isolation Valve Solenoids Trip Test (April 5, 1979)

I Cleaning Boric Acid Tank Level Sensing Lines (May 2, 1979)

NUMBER TITLE-16-REVISION PT-23.17A PT-23.17B Containment Isolation Valve Leak Rate Testing Containment Pressure Sensing Transmitters PT-945 and PT-946 (February 17, 1979)

Containment Isolation Valve Leak Rate Testing Containment Pressure Sensing Transmitters PT-947 and PT-948 (February 14, 1979)

PT-23.17C Containment Isolation Valve Leak Rate Testing Containment Pressure Sensing Transmitters PT-949 and PT-950 (february 12, 1979)

PT-23.18A Containment Isolation Valve Leak Rate Testing

"A" Containment Spray Header (February 21, 1979)

PT-23.18B Containment Isolation Valve Leak Rate Testing "B" Containment Spray Header (February 21, 1979)

'T-23.19 Containment Isolation Valve Leak Rate Testing Safety Injection System (February 21, 1979)

PT-23.23 Containment Isolation Valve Leak Rate Testing Sump "A" Discharge (February 24, 1979)

PT-23.46 Containment Isolation Valve Leak Rate Testing Nitrogen to Accumulators (February 20, 1979)

PT-23.50A PT-23. 50B Containment Isolation Valve Leak Rate Testing Containment Post Accident Air Sample (Clean Int. Building) (February 12,'979)

Containment Isolation Valve Leak Rate Testing Containment Post Accident Air Sample (Controlled Int. Building)

(February 14, 1979)

-18-NUMBER TITLE REVISION T-41D Motor Driven Auxiliary Feed Pump Isolation M-15. 1

"A" or "B" Diesel Generator Removal From

,

Service M-15.3 Maintenance of the 1A Diesel Fuel Oil Transfer Pump M-15.3.1 1A Diesel Generator Solenoid Valves 5907

and/or 5907A Maintenance M-15.3.2 Diesel Generator FLSI, Fuel Oil Level Switch High Maintenance 3'-15.4 Diesel Startup Air Compressor Maintenance

M-16.1 Service Water Discharge Header for Turbine

Building Isolation M-32. 1 DB-25, DB-50 and DB-75 Circuit Breaker Maintenance And Overcurrent Trip Device Test and/or Replacement

.

M-37.0 Repacking of Air Motor Operated Valves M-37. 10 Grinnell Diaphragm Valves, Air Operated, Maintenance M-37. 13 M-37. 14 M-37.15 Inspection and Maintenance of "A" Loop Accumulator Discharge Check Valve V-842B Inspection and Maintenance of."B" Loop Accumulator Discharge Check Valve V-842A Replacing or Adjusting Rubber Seat in Purge Supply and Exhaust Valves M-37.15.1 Inspection and Maintenance 48" Butterfly

Valve Model R-1A8 M-37. 16J Inspection and Maintenance of the Motor Driven Auxiliary Feed Pump Recirculation Control Valve

- 19-NUMBER TITLE REVISION M-37.18H Containment Spray Pump Discharge Check Valve 862A and/or 862B Inspection and Maintenance M-37-18K Repair of the "A" Safety Injection Pump

Discharge Check Valve 889A M-37. 19 M-37.22 M-37. 28 M-37. 29 M-37. 30 Removal of Limitorque Motors and/or

Repacking of Gate Valves 860A, B, C,

and D

Repacking of Accumulator Motor Operated Discharge Valves Inspection and Maintenace of "A" Loop Accumulator Loop Check Valve 867B Inspection and Maintenance of "B" Loop Accumulator Loop Check Valve 867A Repair and Inspection of "A" Accumulator

Fill Valve 835A M-37.31 Repair and Inspection of "A" Accumulator

Test Line Valve 839A M-37. 40 Maintenance on Motor Driven Auxiliary Feedwater Pumps Discharge Valves-MOV-4007 or MOV-4008 M-37.43 M-37. 47 M-38. 5 Accumulator Drain Valves 844A 5 B

Inspection and Repair RHR Pump Suction MOV 851A or B Maintenance

and Inspection 1B Constant Voltage Transformer Maintenance M-38.6 lA Battery Charger Maintenance or Repair

M-38.7 1B Battery Charter Maintenance or Repair 1'

I

-20-NUMBER TITLE REVISION M-38.8 1A1 Battery Charger Maintenance or Repair

N-38.9 M-38. 2 M-38. 3 M-38. 4 M-37. 53 N-37.55 N-38 1B1 Battery Charger Maintenance or Repair

1A Inverter Maintenance or. Repair

1B Inverter Maintenance or Repair

lA Constant Voltage Tr ansformer Maintenance

RHR Core Deluge Valve 852A

B Isolation

and Packing Spray Additive Tank Discharge Valves HCV-836A 8I B Inspection,and/or Maintenance Equalizing Charge - Station Battery Systems

N-42.2 Charcoal filters Installation/Removal

N-44. 1 Isolation and Restoration of Motor Control

Center 1A M-44.2 Isolation and Restoration of Motor Control

Center 1B M-44. 3 Isolation of 1C MCC and Restoring to Service M-44. 4 Isolation of 1D MCC and Restoring to Service M-45.1A Inspection of Safeguard Motor for M-45. 1B Residual Heat Removal Pump Motor Maintenance at Cold Shutdown M-45.4 Safeguard Valve Motors Inspection M-46. 1 Purging Gas from the "A" Accumulator N-46.2 Purging Gas from the "B" Accumulator

- 21.-

NUMBER TITLE REVISION M-48;2 Isolation of Bus

M-48.4 Isolation of Bus

N-48.5 Isolation of Bus

M-48.6 Isolation of Bus

N-48.7 Cross Tie of Bus 17 to Bus

M-51.1 Isolation of a Reactor Protection Relay M-64.1 Periodic Surveillance and Ninor Maintenance

of Limitorque Motor Operated Safeguards Valves N-64.2 Limitorque Valve Operator, Maintenance and

Inspection N-81 Safeguard Rack Ventilation 8 Containment Isolation Relays Replacement Calibration Procedures The listing below comprises the sample of the principal types of calibration procedures maintained by the licensee for ESF systems which were reviewed by the inspector.

The sampling inspection was based on the licensee's use of generic procedure formats for all similar devices.

,

NUMBER TITLE REVISION CP-426.0 Calibration and/or Maintenance of "426" Pressurizer Level Channel CP-426.1 General Defeat Procedure

"426" Pressurizer

Level CP-426.2 General Reinstate

"426" Pressurizer Level

CP-426.3 Pressurizer Level Transmitter LT-426 CP-426.4 Pressurizer Level Power Supply Lg-426

-22-NUMBER TITLE CP-426.5 Pressurizer Level Bistable LC-426A/B CP-426.6 Pressurizer Level Repeater LM-426A RfVISION CP-426.7 CP-426.8 Pressurizer Level Repeater LM-426B Pressurizer Level Indicator LI-426 CP-427.0 Calibration and/or Maintenance of Pressurizer Level Channel

"427" CP-427.1 Defeat of "427" Pressurizer Level CP-427.2 Reinstate

"427" Pressurizer Level CP-427.3 Pressurizer Level Transmitter LT-427 CP-427.4 Pressurizer Level Power Supply Lg-427 CP-427.5 Pressurizer Level Bistable LC-427 A/C CP-427.6 Pressurizer Level Repeater LM-427 CP-427.7 Pressurizer Level Indicator LI-427 CP-428.0 Calibration and/or. Maintenance of Pressurizer Level Channel

"428" CP-428.1 Defeat of "428" Pressurizer Level CP-428.2 Reinstate

"428" Pressurizer Level CP-428.3 Pressurizer Level Transmitter LT-428 CP-428.4 Pressurizer Level Power Supply LI-428 CP-428.5 Pressurizer Level Bistable LC-428 A/f CP-428.6 Pressurizer Level Repeater LM-428A

.

CP-428.7 Pressurizer Level Repeater LM-428B CP-428.8 Pressurizer Level Indicator LI-428

-23-NUMBER TITLE REVISION CP-428.9 Pressurizer Level Recorder LR-428 CP-429.0 Calibration and/or Maintenance of Pressurizer Pressure Channel

"429" CP-429.1 General Defeat Procedure of Pressurizer Pressure Channel

"429" CP-429.2 General Reinstate Procedure of Pressurizer

Pressure Channel

"429" CP-429.3 Pressurizer Pressure Transmitter PT-429

CP-429.4 Pressurizer Pressure Power Supply Pg-429

CP-429.5 Pressurizer Pressure Lead/Lag PM-4298

CP-429.6 Pressurizer Pressure Bistable PC-429A

CP-429.7 Pressurizer Pressure Bistable PC-429B

CP-429.8 Pressurizer Pressure Bistable PC-429C/D

CP-429.9 Pressurizer Pressure Bistable PC-429E

CP-429.10 Pressurizer Pressure Repeater PM-429A

CP-429.11 Pressurizer Pressure Repeater PM-429C

CP-429.12 Pressurizer Pressure Indicator PI-429

CP-429.13 Pressurizer Pressure Recorder PR-429 CP-430.0 Calibration and/or Maintenance of "430" Pressurizer Pressure Channel CP-430.1 General Defeat Procedure

"430" Pressurizer

Pressure Channel CP-430.2 General Reinstate Procedure

"430" Pressurizer Pressure Channel CP-430.3 Pressurizer Pressure Transmitter PT-430

t T

NUMBER TITLE REVISION CP-430.4 Pressurizer Pressure Power Supply Pg-430

CP-430.5 Pressurizer Pressure Lead/Lag Unit PM-430

CP-430.6 Pressurizer Pressure Bistable PC-430A

CP-430.7 Pressurizer Pressure Bistable PC-430 E/F

CP-430.8 Pressurizer Pressure Bistable PC-430 H

CP-430.9 Pressurizer Pressure Repeater PM-430 A

CP-430.10 Pressurizer Pressure Indicator PI-430 CP-431.0 Calibration and/or Maintenance of Pressurizer Pressure Channel

"431" CP-431.1 General Defeat Procedure

"431" Pressurizer

Pressure Channel CP-431.2 General Reinstate Procedure Pressurizer Pressure Channel 431 CP-431.3 Pressurizer Pressure Transmitter PT-431

CP-431.4 Pressurizer Pressure Power Supply Pg-431

CP-431.5 Pressurizer Pr essure Lead/Lag Unit PM-431B

CP-431.6 Pressurizer Pressure Bistable PC-431A

CP-431.7 Pressurizer Pressure Bistable PC-431 I/G

CP-431.8 Pressurizer Pressure Bistable PC-431'P-431.9 Pressurizer Pressure Repeater PM-431A CP-431.10 Pressurizer Pressure Repeater PM-431C CP-431.11 Pressurizer Pressure Indicator PI-431 CP-449.0 Calibration and/or Maintenance of Pressurizer Pressure Channel

"449"

-25-NUMBER TITLE REVISION CP-449.1 General Defeat Procedure for Pressurizer

Pressure Channel P-449 CP-449.2 General Reinstate Procedure for Pressurizer Pressure Channel P-449 CP-449.3 Pressurizer Pressure Transmitter PT-449

CP-449.4 Pressurizer Pressure Power Supply Pg-449

CP-449.5 Pressurizer Pressure Lead/Lag Unit PM-449 B

CP-449.6 Pressurizer Pressurizer Bistable PC-449A

CP-449.7 Pressurizer Pressure Bistable PC-449

2 CP-449.8 Pressurizer Pressure Repeater PM-449 A

CP-449.9 Pressurizer Pressure Repeater PM-449 C

CP-449.10 Pressurizer Pressure Indicator PI-449 CP-449.11 Pressurizer Pressure Indicator PI-449 B

0.

CP-473.0 Calibration and/or Maintenance of Steam Generator Level Channel

"473-"

CP-473.1 Defeat of "B" Steam Generator Level Channel

II4 73 II CP-473.2 Reinstate of "B" Steam Generator Level Channel

"473" CP-473.3 Steam Generator Level Transmitter LT-473

CP-473.4 Steam Generator Level Power Supply Lg-473

CP-473.5 Steam Generator Level Bistable LC-473 C/D

CP-473.6 Steam Generator Level Bistable LC-473 E

CP-473.7 Steam. Generator Level Repeater LM-473 B

-26-NUMBER TITLE CP-473.8 Steam Generator Level Indicator LI-473 CP-475.0 Calibration and/or Maintenance of Steam Flow Channel

"475" CP-475.1 General Defeat Procedure Steam Flow Channel

"475" REVISION CP-475.2 General Reinstate Steam Flow Channel

"475"

CP-475.3 Steam Flow Transmitter FT-475 CP-475.4 Steam Flow Power Supply Fg-475 CP-475.5 Steam Flow Bistable FC-475 A

CP-475.6 Steam Flow Multiplier/Divider Unit FM-475 A

CP-475.7 Steam Flow Square Root Extractor FM-475 B

CP-475.8 Steam Flow Level Repeater FH-475 C

CP-475.9 Steam Flow Repeater FM-475 D

CP-475.10 Steam Flow Indicator FI-475 CP-475. 11 Steam Flow Recorder FR-475 CP-477.0 Calibration and/or Maintenance of Feedwater

Flow Channel

"477" CP-477.1 Defeat of "B" Feedwater Flow Channel

"477"

CP-477.2 Reinstate of "B" Feedwater Flow Channel

II4 77 II CP-477.3 Feedwater Flow Transmitter FT-477 CP-477.4 Feedwater Flow Power Supply Fg-477 CP-477.5 Feedwater Flow Square Root Extractor FM-477 A

l

-27-NUMBER TITLE CP-477.6 Feedwater Flow Bistable FC-477 A/B CP-477.7 Feedwater Flow Repeater FM-477 B

CP-477.8 Feedwater Flow Repeater FM-477 C

CP-477.9 Feedwater Flow Indicator FI-477 CP-477.10 Steam Flow Recorder FR-475 CP-478.0 Calibration and/or Maintenance of Steam Generator Pressure Channel

"478" CP-478.1 Defeat of "B" Steam Generator Pressure Channel

"478" REVISION CP-478.2 Reinstate of "B" Steam Generator Pressure

Channel

"478" CP-478.3 Steam Generator Pressure Transmitter PT-478

CP-478.4 Steam Generator Pressure Power Supply

Pq-478 CP-478.5 Steam Generator Pressure Lead/Lag Unit PM-478A CP-478.6 Steam Generator Pressure Bistable PC-478 A

CP-478.7 Steam Generator Pressure Repeater PM-478 B

CP-478.8 Steam Generator Pressure Repeater PM-478 C

CP-478. 9 ELIMINATED CP-478.10 Steam Generator Pressure Indicator PI-478

CP-501.3 Voltmeter Calibration for 480 V Circuits

Bus 814 (Safeguard)

CP-501.4 Voltmeter Calibration for 480 V Circuits

Bus 817 (Safeguard)

-28-NUMBER TITLE CP-501.5 Voltmeter Calibration for 480 V Circuits Bus 816 (Safeguard)

REVISION CP-501.6 Voltmeter Calibration for 480 V Circuits

Bus

$ 18 (Safeguard)

CP-502. 1 Calibration of lA Emergency Diesel Kilowatt Meter CP-502.2 Calibration of 1B Emergency Diesel Kilowatt Meter CP-617.0 Component Coolant Water Pumps Discharge Pressure CP-619.0 CP-619.1 Component Cool-ing Water Heat Exchanger Outlet Flow L.oop "619" Component Cooling Water Heat Exchanger Outlet Flow Transmitter PT-619 CP-619.2 Component Cooling Water Heat Exchanger Outlet Flow Power Supply, Fg-619 CP-619.3 Component Cooling Mater Heat Exchanger Outlet Flow Bistable FC-619B CP-619.4 Component Cooling Water Heat Exchanger Outlet Flow Indicator FC-619B CP-624. 1 Residual Heat Removal Heat Exchanger Outlet

Valve HCV-624 Isolation CP-625.1 Residual Heat Removal Heat Exchanger Outlet

Valve HCV-625 Isolation CP-626.0 Calibration and/or Maintenance of Residual

Heat Removal Flow Channel

"626" CP-626. 1 Defeat of Residual Heat Removal Flow Channel

"626"

-29-NUMBER TITLE REVISION CP-626.2 CP-626.3 Reinstate of Residual Heat Removal Flow Channel

"626" S

Residual Heat Removal Flow Transmitter FT-626 CP-626.4 Residual Heat Removal Power Supply Fg-626

CP-626.5 Residual Heat Removal Flow Channel Bistable

FC-626B CP-626.6 Residual Heat Removal Flow Square Root Extr actor FM-626

CP-626.7 Residual Heat Removal Flow Indicator FI-626

CP-626.8 Residual Heat Removal Flow Channel Recorder

FR-626 CP-626.9 Residual Heat Removal Flow Channel Controller FC-626A CP-626. 10 Residual Heat Removal Flow Channel Control

Valve Operator on FCV-626 CP-628.0 RHR Loop Reactor Coolant Test Bypass Flow

CP-701 Turbine Driven Auxiliary Feedwater Pump

Oil Pressure Regulator Adjustment CP-920.0 Calibration and/or Maintenance

"920" Refueling Hater Storage Tank Level Channel CP-920. 1 Placing of Refueling Mater Storage Tank Level Channel

"920" Out-of-Service CP-920.2 Placing of Refueling Water Storage Tank

'Level Channel

"920" In-Service CP-920.3 Refueling Mater Storage Tank Level Transmitter LT-920

-30-NUMBER TITLE REVISION CP-920.4 Refueling Water Storage Tank Level Power

Supply Lg-920 CP-920-5 Refueling Water Storage Tank Level Bistable

LC-920 A/B CP-920.6 Refueling Water Storage Tank Level Bistable

LC-920 C

CP-920.7 Refueling Water Storage Tank Level Indicator LI-920 CP-921.0 Calibration and/or Maintenance Procedure

for Refueling Water Storage Tank Level Indicating Alarm CP-922.0 Calibration of Safety Injection Pump Discharge Pressure Transmitter - PT-922 and Associated Indicators CP-923.0 Calibration of Safety Injection Pump Discharge Pressure Transmitter - PT-922 and Associated Indicators CP-924.0 CP-924.1 Calibration and/or Maintenance of Safety Injection Flow Loop "B" Calibration and/or Maintenance of Safety Injection Loop "A" Transmitter FT-924 CP-924.2 Calibration and/or Maintenance of Safety

Injection Flow Loop "B" Power Supply Fg-924 CP-924.3 Calibration and/or Maintenance of Safety

Injection Flow Loop "B" Square Root Extractor Unit FM-924 CP-924.4 Calibration and/or Maintenance of Safety

Injection Flow Loop "B" Indicator FI-924 CP-925.0 Calibration and/or Maintenance of Safety Injection Flow Loop A

-31-NUMBER TITLE REVISION CP-925. 1 Calibration and/or Maintenance of Safety

Injection Flow Loop "A" Transmitter FT-925 CP-925.2 Calibration and/or Maintenance of Safety

Injection Flow Loop "A" Power Supply Unit FQ-925 CP-925.3 Calibration and/or Maintenance of Safety

Injection Flow Loop "A" Square Root Extractor FM-925 CP-925.4 Calibration and/or Maintenance of Safety

Injection Flow Loop "A" Indicator FI-925 CP-930.0 Calibration and/or Maintenance of Spt ay Additive Tank Inlet Flow Transmitter Loop CP-931.0 'alibration and/or Maintenance of Spray Additive Tank Level Channel

"931"

'P-931.1 Spray Additive Tank Level Transmitter LT-931 CP-931.2 Spray Additive Tank Level Transmitter Bistable LC-931 CP-931.3 Spray Additive Tank Level Indicator LI-931

CP-931A CP-931B Calibration of R.H.R. Refueling Water Return Line Flow Transmitter and Associated Indicators Calibration of R.H.R. Refueling Water Return Line Flow Transmitter and Associated Indicators CP-932.0 Calibration and/or Maintenance of Spray Additive Tank Level Transmitter and Indicator CP-933A Containment Spray Discharge Header Pressure A

-32-NUMBER TITLE CP-933B.O Containment Spray Discharge Header Pressure CP-933C.O

"A" Containment Spray Pump Discharge Pressure Gauge PI-933C CP-933D.O

"B" Containment Spray Pump Discharge Pressure Gauge PI-933D REVISION CP-934.0 Calibration and/or Maintenance Procedure of

Accumulator Level Channel

"934" CP-934.1 Accumulator Level Transmitter LT-934 CP-934.2 Accumulator Level Bistable LC-934 CP-934.3 Accumulator Level Local Indicator LI-934 CP-934.4 Calibration and/or Maintenance of Accumulator Level Power Supply Lq-934 CP-935.0 Calibration and/or Maintenance of Accumulator Level Channel

"935" CP-935.1 Accumulator Level Transmitter LT-935 CP-935.2 Accumulator Level Bistable LC-935 A/B CP-935.3 Accumulator Level Indicator LI-935 CP-935. 4 Cal ibration Accumul ator CP-936. 0 Cal ibrati on Accumul ator and/or Maintenance of Level Power Supply Lg-935 and/or Maintenance of Pressure Channel

"936" CP-936.1 Accumulator Pressure Transmitter PT-936 CP-936.2 Accumulator Pressure Power Supply Pg-936 CP-936.3 Accumulator Pressure Channel Bistable PC-936 A/B

-33-NUMBER TITLE REVISION CP-936.4 Loop "A" Accumulator Pressure Local Indicator CP-937.0 Calibration-and/or Maintenance of Accumulator Pressure Channel

"937" CP-937.1 Accumulator Pressure Transmitter PT-937

CP-937.2 Accumulator Pressure Power Supply Pg-937

CP-937.3 Accumulator Pressure Bistable PC-937 A/B

CP-937.4 Accumulator Pressure Indicator PI-937 CP-938.0 Calibration and/or Maintenance of Accumulator Level Channel

"938" CP-938. 1 Accumulator Level Transmitter LT-938 CP-938.2 Accumulator Level Bistable LC-938 A/B CP-938.3 Accumulator Level Indicator LI-938 CP-938.4 Calibration and/or Maintenance of Accumulator Level Power Supply Lg-938 CP-939.0 Calibration and/or Maintenance of Accumulator Level Channel

"939" CP-939.1 Accumulator Level Transmitter LT-939 CP-939.2 Accumulator Level Bistable LC-939 A/B CP-939.3 Accumulator Level Indicator LI-939 CP-939.4 Calibration and/or Maintenance of Accumulator Level Power Supply Lg-939 CP-940.0 Calibration and/or Maintenance of Accumulator Pressure Channel

"940" CP-940.1 Accumulator Pressure Transmitter PT-940

l

NUMBER TITLE REVISION CP-940.2 CP-940.3 CP-940.4 CP-941.0 CP-941. 1 CP-941. 2 Accumulator Pressure Power Supply PC-940 Accumulator Pressure Bistable PC-940 A/B

Accumulator Pressure Local Indicator PI-940

'I Calibration and/or Maintenance of

Accumulator Pressure Channel

"941"

Accumulator Pressure Transmitter PT-941

Accumulator Pressure Power Supply Pg-941

CP-941.3 Accumulator Pressure Bistable PC-941 A/8

CP-941.4 Accumulator Pressure Local Indicator PI-941

CP-942.0 Check and/or Maintenance of Containment

Sump 81 Level Switches and Indicating Lights CP-943.0 Check and/or Maintenance of Containment Sump B82 Level Switches and Indicating Lights CP-944.0 Containment Pressure Loop 944 CP-944.1 Containment Pressure Loop Transmitter PT-944 CP-944.2 Containment Pressure Loop Indicator PT-944

CP-945.0 Calibration and/or Maintenance of Containment Pressure Channel

"945" CP-945. 1 Defeat of "A-1" Containment Pressure Channel

"945" CP-945.2 Reinstate of "A-1" Containment Pressure Channel

"945" CP-945.3 Containment Pressure Transmitter PT-945

-35-NUMBER TITLE CP-945.4 Containment Pressure Power Supply Pg-945 CP-945.5 Containment Pressure Bistable PC-945 A/B CP-945.6 Containment Pressure Repeater PM-945 REVISION

CP-945.7 CP-946.0 Containment Pressure Indicator PI-945 Calibration and/or Maintenance of Containment Pressure Channel

"946" CP-946.1 Defeat of "A-2" Containment Pressure Channel

"946" CP-946. 2 Reinstate of "A-2" Containment Pressure

,

Channel

"946" CP-946.3 Containment Pr essure Transmitter PT-946

CP-946.4 Containment Pressure Power Supply Pg-946

CP-946.5 Containtment Pressure Bistable PC-946 A/8

CP-946.6 Containment Pressure Repeater PM-946

CP-946.7 Containment Pressure Indicator PI-946

CP-947.0 Calibration and/or Maintenance of, Containment Pressure Channel

"947" CP-947. 1 Defeat of "A-3" Containment Pressure Channel

"947" CP-947.2 Reinstate

"A-3" Containtment Pressure Channel

"947" CP-947.3 Containment Pressure Transmitter PT-947 CP-947.4 Containment Pressure Power Supply Pg-947

CP-947.5 Containment Pressure Bistable PC-947 A/B

CP-947.6 Containment Pressure Repeater PM-947

-36-NUMBER TITLE CP-947. 7 Containment Pressure Indicator PI-947 CP-948.0 Calibration and/or Maintenance of Containment Pressure Channel

"948" REVISION CP-948. 1 CP-2007.0 Defeat of "B-2" Containment Pressure

Channel

"948"

Turbine Driven Auxiliary Feedwater Flow

~

to Steam Generator 1B, Loop 2007 CP-2019.0 Turbine Driven Auxiliary Feedwater Pump Discharge Pressure Loop 2019 CP-2022.0 Condensate Storage Tank Level CP-2022. 1 Condensate Storage Tank Level Transmitter

'T-2022 CP-2022.2 Condensate Storage Tank Level Bistable LC-2022 CP-2022.3 Condensate Storage Tank Level Power Supply Lg-2022 CP-2022.4 Condensate Storage Tank Level Indicators,

LI-2022 CP-2029.0 1A Motor Driven Auxiliary Feedwater Pump Discharge Pressure Loop 2029 CP-2030.0 1B Motor Driven Auxiliary Feedwater Pump Discharge Pressure Loop 2030 CP-2001.0 1A Motor Driven Auxiliary Feedwater Pump Discharge Flow Loop 2001 CP-2002.0 1B Motor Driven Auxiliary Feedwater Pump Discharge Flow Loop 2002 CP-2006.0 Turbine Driven Auxiliary Feedwater Flow to Steam Generator lA, Loop 2006

d.

~Findin s

During review of monthly Periodic Test PT-12.2, Emergency Diesel 18, Revision 10, which was performed-on April 12, 1979, the inspector noted that the data for diesel engine water jacket pressure indicated a pressure of 3 psig rather than the approximate 33 psig normal operating pressure.

The completed procedure had been reviewed and signed by the reviewing parties, apparently without noting the discrepant data.

The auxiliary operator who had performed the test was interviewed and could not confirm that an error in data recording had taken place although all other engine parameters relying on jacket cooling water appeared normal.

On the basis that, if accurate, the abnormally low cooling pressure would render the diesel generator inoperable, the licensee immediately performed the above test (on May 9, 1979) with satisfactory results.

All parameters displayed normal equipment performance.

On May 10, 1979, during review of records for PT-16, Auxiliary Feedwater System, Revision 19, the inspector determined that the results of the last performance of the monthly test on April 24, 1979, had not been re-viewed and approved as acceptable.

The licensee immediately reviewed the subject test results and determined them to be satisfactory with all acceptance criteria having been met.

The inspector's review of the test results confirmed the licensee's finding.

Failure to perform adequate and timely reviews of test results to assure that test requirements have been satisfied is contrary to 10CFR50, Appendix 8, Criterion XI; the Ginna Station quality Assurance Manual, Section 11, Test Control, Revision 6; and, Administrative Procedure A-1104, Ginna Station Technical Specification Surveillance Program, Section 3.3, Revision 0, and con-stitutes an Infraction level item of noncompliance (244/79-08-05).

(2)

During review of Maintenance Instructions and Calibration Procedures, the inspector noted that the licensee did not, in all cases, provide discrete, valve by valve, return to service alignment instructions in the procedure In some cases, administrative controls for the use of Hold Tags were utilized to ensure proper return to service..

In other cases, a valve alignment for main-tenance was specified discretely in the procedure but the return to service instructions consisted of a general statement to return the valves affected to their normal operating alignment following the maintenance.

The licensee's reponse to IEB 79-06A, Revision 1, Item 8, indicates that these procedures will be reviewed and revised as necessary to ensure that such valves are. returned to their proper positions following maintenance.

The inspector informed licensee management that itemized return to normal checklists or procedure steps should be provided for this function.,

Reliance upon general statements directing such activities should be avoided.

The licensee s actions in this regard will be reviewed during subsequent inspections.

(244/79-08-06)

6.

Surveillance Procedure Controls for Pressurizer Level Bistables Placed in t e Tri ed Condit)on In accordance with the direction provided in IE Bulletin 79-06A, the licensee has placed the Pressurizer Level Safety Injection Bistables in a tripped condition.

In order to control the status of these bistables during maintenance, calibration, or periodic testing, the licensee has issued procedure A-64, Pressurizer Level Safety Injection Bistables, Revision 0, April 19, 1979.

This procedure provides instructions for resetting and retripping the bistables as necessary to support maintenance activities without inducing unwanted, inadvertent Safety Injection actuations.

The procedure removes all bistables from the trip mode prior to work or testing on any of the three channels and promptly restores them to the tripped condition upon completion of the work, including verification of the respective bistable status lights for each condition.

7.

Administrative Controls for ESF S stem Return to Service Followin Maintenance, Testin or Extended Outa e

The inspectors reviewed the licensee's administrative controls to ensure that they adequately provide for prop'er return to service of ESF components following test and maintenance activities and at the conclusion of extended outages.

The following procedures were reviewed and appear to adequately address proper realignment

-39-of systems, verification of system operability through inspection or testing, and positive control of system status and status information throughout operations or maintenance evolutions.

NUMBER.

TITLE REVISION A-46 A-52.2 Bypass of Safety Function or J<>p'8r, Control

Control of Locked Valve Operation

A-52.3 Starting and Stopping of Plant Equipment

A-52.4 Control of Limiting Conditions for Operating Equipment A-52.5 Control of Limiting Conditions for System Specifications A-1103 Test Tag Control Program A-1401 Station Holding Rules A-502 Plant Procedure Content and Format Requirements

A-503 0-1.1 Plant Procedure Adherence Requirements Plant Heatup from Cold Shutdown to Hot Shutdown

39 0-1.1C Precritical Technical Specification Checksheet 0.1.1D Preheatup Plant Requirements Check List No items of noncompliance were identified.

8.

Inde endent Verification of S stem Ali nment

The licensee's administrative controls are presently being revised to provide for the following methods of independent verification:

a.

System Operating Procedures have been issued to verify selected ESF System valve positions at intervals between normal surveillance testing of the systems.

These procedures are:

I

- 40-S-30.1, Sl System Valve Position Verification, Revision 1, April 18, 1979.

S-30.2, RHR System Valve Position Verification, Revision 0, April 11, 1979.

S-30.3, Containment Spray Valve Position Verification, Revision 0, April 11, 1979.

S-30.4, Auxiliary Feedwater System Valve Position Verification, Revision 0, April 19, 1979.

These procedures provide independent verification of critical flow paths between routine surveillance test performances to assure that systems have been properly aligned at the completion of the surveillance and have not been disturbed since that time.

b.

The licensee is also preparing revisions to Periodic (sur-veillance) Tests which will provide for indepen'dent verification of system alignment at the completion of each test by having an operator other than the test performer verify the system's return to service lineup.

c ~

The licensee's Operating Procedure 0-6;2, Main Control Board System Status Verification, Revision 5, is now being performed twice per shift versus the prior once per shift performance.

0-6.2 provides for verification of key system status items from the Main Control Board for ESF systems and systems required for safe shutdown.

d.

The licensee's task force, formulated to direct the efforts taken in response to the TMI-2 event, is also studying other methods and needs for additional independent verifica-tion.

Except for that provided by performance of the checks and tests described above, the licensee does not currently require independent (multi-party) verification of system alignment following extended outages.

The administrative controls in effect for ESF system restoration following outages are discussed in paragraph 7.

In that the licensee's actions are ongoing in regard to items b) and d) above, they will be reviewed during future inspections (244/79-08-07).

I

-41-Auxiliar Feedwater S stem AR(

Valve Ali nment The licensee requires that key valves in the Auxiliary Feedwater System be locked in position and administratively controlled in accordance with Administrative Procedure A-52.2, Control of Locked Valve Operation, Revision 24, April 9, 1979.

The inspector and the Plant Operations Supervisor conducted a

verification of these valves on May 2, 1979, confirming that the valves are properly positioned and locked.

The inspector noted that the locked valves were principally located in the AFM pump suction path.

The remaining valves in the AFW discharge flow path were verified to be properly positioned on May 15, 1979 by the inspector and a licensed operator.

The entire system was walked down by the inspector and an operator confirming that all system valves were positioned in accordance with Procedure T-41A, Alignment of Auxiliary Feedwater System prior to Power Operation, Revision 13, and capable of accident response.

Partial Actuation of Safet In 'ection SI for Routine 0 eratlonal Events.

At the time of this inspection, the licensee had not required partial SI actuation to accommodate routine operational events which result in decreasing plant pressure or pressurizer level Operating experience for such events has shown that the plant responds adequately without such action being required.

Any event which cannot be accommodated by normal charging system operation will result in full automatic safety injection.

initiation or full manual safety injection initiation when the set points for auto initiation are reached.

The licensee had issued a directive to operators on April 18, 1979 which reemphasized the requirement to manually initiate safety injection if an automatic initiation set point is exceeded.

Reactor Coolant Pum s - Post-Event 0 eratin Procedures The licensee's response to IEB 79-06A, Revision I, states that all Emergency Procedures for LOCA and Steam Break Accidents now require that all operating RCP's be tripped.

Based on recommenda-tion from the utility's NSSS vendor, the subject procedures will not be revised in the short term to provide for continued opera-tion of an RCP during or after such an even T

-42-As a long term effort, the licensee intends to modify Emergency Procedures to clarify the conditions under which the pumps are to be tripped.

Pending further review by NRC of the licensee's response and actions in this regard, the acceptability of the licensee's response to this item is unresolved.

(244/79-08-09)

Procedures for Feedin Dr Steam Generators The licensee's procedures do not address the methods required to add feedwater to a steam generator which has sustained a complete dry-out on loss of feedwater.

Consistent with the facility's NSSS vendor recommendations, the licensee's Emergency and Operating Procedures do provide for controlling the rate of feedwater addition to a steam generator experiencing an abnormal but detectable low water level condition in order to prevent feed line water hammer.

These procedures stipulate that feedwater addition be limited to less than 150 gpm at any time narrow range indicated Steam Generator level is less than 15$.

This feedwater addition rate is to be maintained until level is restored to greater than 305.

The procedures provide for feed rates from the Auxiliary Feedwater System which are in excess of 200 gpm when narrow range Steam Generator level is less than 5$ and Safety Injection actuation has occurred.

While the procedures do not provide for the circumstance of a completely dry Steam Generator, guidance is provided for extreme low level conditions.

Discussions with onshift operators confirmed that they were aware of and understood the existing procedural guidance.

The procedural guidance is contained in the following procedures:

0-1.1 Plant Heatup from Cold Shutdown to Hot Shutdown, Revision 39.

0-1. 2 0-2.1 0-2.2 Plant Heatup from Hot Shutdown to Steady Load, Revision 47.

Normal Shutdown to Hot Shutdown, Revision 25.

'lant Shutdown from Hot Shutdown to Cold Condition, Revision 3 o J

Ls

- 43-0-2.4 Plant Shutdown from Hot Shutdown to Cold Shutdown During Blackout, Revision 18.

0-2.5 Plant Shutdown from Hot Shutdown to Cold Shutdown When Condenser Steam Dump is Unavailable, Revision 12.

E-29.1 Loss of Normal Feedwater (Not Recoverable),

Revision 3.

13.

Control Board Ta in Practices As currently established, Procedure A-1401, Station Holding Rules, Revision 0, provides for use of safety tags which have the potential for obscuring control board indication.

Procedure A-1103, Test Tag Control Program, Revision 0 provides for use of similar tags for use during testing.

The inspector, observed that very few tags are used during plant operation and those are carefully placed to minimize obscuring of operator indications.

In that most maintenance activities are conducted during shutdown periods, the licensee finds it necessary to post only a minimal number of tags on operating panels during operation and those only for limited time periods.

The licensee's existing practices and policies appear adequate to prevent hazardous obscuring of control board indications.

14.

Licensee Actions in Res onse to IE Bulletin 79-06A, Revision

During this inspection, the licensee submitted.the response to IE Bulletin 79-06A, Revision 1, Review of Operational Errors and

.

System Misalignments Identified during the Three Mile Island Incident.

The inspector reviewed the licensee's actions to ensure that:

The written response was submitted within the required time period; The response includes the information required to be reported; The response includes adequate corrective action commitments based upon the information provided in the bulletin; Licensee management forwarded copies of the written response to appropriate onsite management; Information discussed in the response was adequate; and,

4 Corrective action was being taken by the licensee as described in the written response.

The licensee has formulated a task force which coordinated pre-paration of the written response and which is administering the implementation of the corrective actions described in the response.

The task force and licensee management are interfacing with their NSSS vendor and NSSS owner's groups in their efforts.

The inspector observed a high level of involvement of both corp-orate and site personnel in the development and implementation of these corrective actions.

A technical review of the licensee's response is being conducted by an NRC Headquarters Task Force.

The inspector conducted a

preliminary review of this response and the early phases of its implementation resulting in the following observations:

The licensee's response is at variance with several of the directives provided by the bulletin including the criteria for securing safety injection flow under small break LOCA conditions and the criteria for continued operation of Reactor Coolant Pumps under LOCA/depressurization conditions.

The inspector noted that where the licensee's response

'ppeared to deviate from the direction provided by the bulletin, the response was consistent with advice provided to the licensee by the NSSS vendor.

The licensee response does not specify the plans and schedule for completing each of the actions identified in the response including completion of necessary procedure revisions.

The inspector observed that the licensee is proceeding with each of the items but has not yet formally identi'fied commitment dates for the completion;

- Pending completion of the technical review of the licensee's response by NRC and review of the corrective action implementation by NRC:RI, this item is unresolved (244/79-08-08).

15.

Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable, items of noncompliance, or deviations.

Unresolved items identified during this inspection are discussed in paragraphs 2, 3, 5 and 1 V

~'1

-45-16.

Exit Interview A management meeting was held with licensee representatives at the close of this inspection on May 18, 1979.

The scope and findings of the inspection as discussed in this report were pr esented.

I

4'l